NSW head of asbestos coordination authorities

Submission No 28

INQUIRY INTO LOOSE FILL ASBESTOS INSULATION Organisation: NSW Head of Asbestos Coordination Authorities

Date received: 31/10/2014

Joint Select Committee on Loose Fill

Asbestos Insulation

Inquiry into Loose Fill Asbestos

Insulation

Submission from the Heads of Asbestos

Coordination Authorities

October 2014

2 Inquiry into Loose Fill Asbestos – HACA submission

Contents

Introduction ........................................................................................................................... 4

What is asbestos? ............................................................................................................. 4

How can asbestos affect individual’s health? ..................................................................... 5

When does asbestos pose a risk to health? ...................................................................... 5

When are householders likely to be exposed to asbestos? ................................................ 6

Different forms of asbestos material, different risk levels ................................................... 9

What is loose fill asbestos insulation? ............................................................................. 10

Management of loose fill asbestos insulation ................................................................... 11

Actions taken by NSW government on loose fill asbestos insulation ................................... 13

Number of homes with loose fill asbestos insulation ........................................................... 15

Number of homes in NSW ............................................................................................... 15

Number of homes and action taken in other jurisdictions ................................................. 17

Australian Capital Territory ........................................................................................... 17

United States of America ............................................................................................. 17

United Kingdom & Northern Ireland.............................................................................. 18

Canada ........................................................................................................................ 18

Asbestos control framework – the role of state, local governments and property owners .... 19

Role of governments ....................................................................................................... 19

Asbestos prohibition ........................................................................................................ 21

Asbestos management requirements .............................................................................. 21

Asbestos removal requirements ...................................................................................... 24

Coordination arrangements ............................................................................................. 25

State-wide asbestos plan................................................................................................. 26

Model policy for NSW councils ........................................................................................ 26

Asbestos awareness campaign ....................................................................................... 27

Further information .............................................................................................................. 30

ATTACHMENT A — United States Environmental Protection Agency – vermiculite insulation

advice. ................................................................................................................................ 31


ATTACHMENT B — United States Environmental Protection Agency Advice – vermiculite

insulation campaign ............................................................................................................ 32

ATTACHMENT C — United Kingdom Health and Safety Executive Advice ........................ 34

ATTACHMENT D — WorkSafe British Columbia, Canada Advice ...................................... 35


Introduction

This submission is made on behalf of the Heads of Asbestos Coordination Authorities

(HACA). The HACA was established by the NSW Government in August 2011 to co-ordinate

the activities of statutory authorities in relation to all aspects of asbestos information,

assistance, compliance and enforcement. The HACA has developed the State-wide

Asbestos Plan to secure the safe management of asbestos and to reduce the incidence of

asbestos-related diseases in New South Wales.

The general information provided in this submission has been extracted from the plans,

blueprint and resource documents developed by the HACA. The documents are available on

the HACA website at:

http://www.workcover.nsw.gov.au/newlegislation2012/asbestos/Pages/headsofasbestoscoor

dinationauthorities.aspx

What is asbestos?

Asbestos is the generic term for a number of fibrous silicate minerals. There are two major

groups of asbestos:

the serpentine group contains chrysotile, commonly known as white asbestos

the amphibole group contains amosite (brown asbestos) and crocidolite (blue

asbestos), as well as some other less common types, such as tremolite, actinolite

and anthophyllite.

Asbestos was commonly mixed with cement to form products such as fibro sheets, pipes

and gutters, under floor packing and has been used in the manufacture of building and

insulation materials, brake linings in motor vehicles, and gaskets for some appliances. It was

also woven into fabric and used for pipe lagging, boiler insulation and loose roof insulation.

http://www.workcover.nsw.gov.au/newlegislation2012/asbestos/Pages/headsofasbestoscoordinationauthorities.aspx

http://www.workcover.nsw.gov.au/newlegislation2012/asbestos/Pages/headsofasbestoscoordinationauthorities.aspx


How can asbestos affect individual’s health?

Breathing in asbestos fibres can cause asbestosis, lung cancer and mesothelioma. The risk

of contracting these diseases increases with the number of fibres inhaled and the risk of lung

cancer from inhaling asbestos fibres is also greater for smokers. People who get health

problems from inhaling asbestos have usually been exposed to high levels of asbestos for a

long time. The symptoms of these diseases do not usually appear until about 20 to 30 years

after the first exposure to asbestos.

When does asbestos pose a risk to health?

Asbestos fibres can pose a risk to health if airborne, as inhalation is the main way that

asbestos enters the body. Small quantities of asbestos fibres are present in the air at all

times, and are being breathed by everyone without any ill effects. Most people are exposed

to very small amounts of asbestos as they go about their daily lives and do not develop

asbestos-related health problems. Finding that your home or workplace is made from fibro

products does not mean your health is at risk. Studies have shown that these products, if in

sound condition and left undisturbed, are not a significant health risk. If the asbestos fibres

remain firmly bound in cement, generally you do not need to remove the fibro.

People who have suffered health effects from exposure to asbestos have generally worked

in either the asbestos mining or milling industry, worked in industries involved in making or

installing asbestos products, or are from the immediate families of these people. In all of

these situations there was exposure to high levels of airborne dust, from either the

processes involved or from the clothes of the workers.


When are householders likely to be exposed to asbestos?

Residential properties built or renovated before 1987 are likely to contain asbestos. The

manufacture and supply of all asbestos-containing materials has been banned in Australia

since 31 December 2003. The following diagram identifies the types of asbestos materials

found in houses in New South Wales.

(Source: NSW State-wide Asbestos Plan)

The Commonwealth Enhealth1 publication advises that:

We are all exposed to low levels of asbestos in the air we breathe every day. Ambient or

background air usually contains between 10 and 200 asbestos fibres in every 1,000 litres (or

cubic metre) of air (equivalent to 0.01 to 0.20 fibres per litre of air). However, most people do

not become ill from this exposure, because the levels of asbestos present in the environment

are very low.

Most people are also exposed to higher levels of asbestos at some time in their lives; for

example, in their workplace, community or home. However, for most people, this kind of

infrequent exposure is also unlikely to result in any ill effects.

1 Asbestos: A guide for householders and the general public, Australian Health Protection Principal Committee, Environment

Health Standing Committee, Commonwealth of Australia 2013.


Most people who develop asbestos-related diseases have worked on jobs where they

frequently breathed in large amounts of asbestos fibres. For example, in the past,

construction workers using unsafe practices may have frequently encountered asbestos fibre

levels well above background levels.

The current regulated workplace limit (over an eight-hour period) is 100 fibres per litre of air

(which is between 500 and 10,000 times background levels). In the past, workers in asbestos

milling or mining often encountered fibre concentrations a million times higher than

background levels.

The World Health Organisation (WHO) Air Quality Guidelines (Second Edition, Page 3)

identify the following typical exposure in different non-occupational settings:

rural areas (remote from asbestos emission sources), below 100 F/m3 (fibres per

cubic metre)

Urban areas, general levels may vary from below 100 to 1,000 F/m3

Near various emission sources the following figures have been measured as yearly

averages:

at a street crossing with heavy traffic, 900 F/m3

on an express-way, up to 3,300 F/m3

in buildings without specific asbestos sources, concentrations are generally below

1,000 F/m3

in buildings with friable2 asbestos, concentrations vary irregularly; usually less than

1,000 F*/m3 are found, but in some cases exposure reaches 10,000 F*/m3, where F*

= fibres counted with an optical microscope

The United States of America (USA) Agency for Toxic Substances and Disease Registry

(ATSDR) – Toxicological Profile for Asbestos (2001, page 3) states:

Low levels of asbestos that present little, if any, risk to your health can be detected in

almost any air sample. For example, 10 fibres are typically present in a cubic meter

(fibres/m3

) of outdoor air in rural areas. (A cubic meter is about the amount of air that

you breathe in 1 hour), Health professionals often report the number of fibres in a

milliliter (mL) (equivalent to a cubic centimeter [cm3

]) of air rather than in a cubic

meter of air. Since there are one million cm3

(or one million mL) in a cubic meter,

2 The Work Health and Safety Regulation 2001 defines friable asbestos to mean material that is in a powder form or that can be crumbled, pulverised or reduced to a powder by hand pressure when dry, and contains asbestos.


there typically would be 0.00001 fibres/mL of asbestos in air in rural areas. Typical

levels found in cities are about 10-fold higher.

In indoor air, the concentration of asbestos depends on whether asbestos was used

for insulation, ceiling or floor tiles, or other purposes, and whether these asbestos-

containing materials are in good condition or are deteriorated and easily crumbled.

Concentrations measured in homes, schools, and other buildings that contain

asbestos range from about 30 to 6,000 fibres/m3

(0.00003–0.006 fibres/mL).

The ATSDR Report (page 159) quotes the Health Effects Institute3 estimate for non-

occupational exposures in rural and urban levels at about 1x10-5

(0.00001) TEM f/mL (fibres

per millilitre) (2x10-7

(0.0000002) PCM f/mL) and 1x10-4

(0.0001) TEM f/mL (2x10-6

(0.000002) PCM f/mL), respectively. TEM (transmission electron microscopy) and PCM

(phase contrast microscopy) are two different analytical techniques with PCM the standard

technique used in Australia.

The testing of NSW homes with loose-fill asbestos insulation (The Queanbeyan Study4) in

1993 found one fibre in one sample, and one fibre in one sample from the control (non-loose

fill insulation houses) and reported that the levels were below the level of practical detection.

Although we have used calculated values in the table, it is incorrect to report fibre

counts below the practical detection limit of the method. For instance the reporting of

one fibre in the analysis for the above sample would give approximately 0.0005 to

0.000007 fibres/mL [fibres per millilitre] of air based on the sample volume range.

This calculated value in not a real value and is statistically no different to zero fibres

in the analysis

The most recent report from the Australian Mesothelioma Registry identifies 137 cases of

mesothelioma from non-occupational asbestos exposure and the potential source identified

through a questionnaire and telephone interview. There are methodological problems in

interpreting these data that greatly limit any interpretation that can be drawn from these data.

3 Health Effects Institute. Asbestos in public and commercial buildings: A literature review and

synthesis of current knowledge. Report of the asbestos literature review panel. Cambridge, MA: Health Effects Institute, 1991. 4 Queanbeyan Study, Asbestos in Private Homes, South Eastern Public Health Unit, NSW Health

Department,1993. Available at: http://www.workcover.nsw.gov.au/formspublications/publications/Documents/queanbeyan-study-NSW-health.pdf

http://www.workcover.nsw.gov.au/formspublications/publications/Documents/queanbeyan-study-NSW-health.pdf

http://www.workcover.nsw.gov.au/formspublications/publications/Documents/queanbeyan-study-NSW-health.pdf


Figure 1: Sources of non-occupational exposure amongst participants without occupational exposure

(source: 3rd Annual Report: Mesothelioma in Australian 2013, Australian Mesothelioma Registry)

Different forms of asbestos material, different risk levels

If asbestos fibres are in a stable material, such as bonded in asbestos-cement sheeting such

as fibro and in good condition, they pose little health risk. However, where fibro or other

bonded asbestos sheeting is broken, damaged or mishandled fibres can become loose and

airborne posing a risk to health. Disturbing or removing it unsafely can create a hazard.

In materials such as pipe lagging and sprayed roof insulation asbestos fibres are not bound

in a matrix. High concentrations of fibres are much more likely to be released into the

atmosphere when these materials are disturbed or removed.

The following list ranks different types of asbestos according to the likelihood that airborne

asbestos can be released into the air if it has deteriorated or been disturbed. The potential

risk to health is greater for items higher up the list if people are exposed to airborne

asbestos, but any of the materials listed can produce asbestos fibres if they are disturbed.


(Source: NSW State-wide Asbestos Plan)

What is loose fill asbestos insulation?

Loose fill asbestos insulation is raw asbestos (usually amosite asbestos but can be

crocidolite asbestos) that has been crushed into a fine state and installed in the ceiling

space. This means it is easy to disturb and fibres can become airborne and easily inhaled or

ingested which can cause significant health risks.

Testing of homes with loose-fill asbestos insulation (The Queanbeyan Study5) indicates that

exposure is likely to be very low if the asbestos is undisturbed and remains sealed off at all

points where entry of asbestos into living areas can occur (including cornices, architraves,

around vents, around light fittings, manholes and tops of cupboards).

The HACA advises that homeowners, living in residential premises with loose fill asbestos

insulation, should not undertake any refurbishment work that requires:

alteration toany walls, ceilings, wall sockets

removal of cornices,

cabling (unless surface mounted) or additional sockets/outlets recessed in walls

accessing subfloor areas

until further assessment under controlled conditions can be conducted.

5 Queanbeyan Study, Asbestos in Private Homes, South Eastern Public Health Unit, NSW Health

Department,1993.


Management of loose fill asbestos insulation

The enHealth document6 (Management of asbestos in the non-occupational environment)

provides information to help promote a nationally consistent approach to investigating and

managing the risk of asbestos in the non-occupational environment. It is designed to assist

environmental health agencies in effective and efficient management of asbestos issues in

these environments. The publication states (page18):

Thermal and acoustic insulation materials were not routinely used in residential

dwellings, although there have been some isolated cases7. If removal is required, it

should be done in accordance with occupational health and safety legislation.

Public and commercial buildings may contain large quantities of loose, friable

asbestos (e.g. insulation), which pose a significant risk of generating airborne fibres if

disturbed. Products of most concern from a health viewpoint include:

sprayed-on fireproofing, soundproofing and/or thermal insulation

acoustic plaster soundproofing

insulation, e.g. of internal air-conditioning ducts, pipes, boilers, fire doors,

heaters, oven doors

sprayed-on fibre used to strengthen asbestos cement sheeting and

decorative finishes.

Exposure

Corn (1994)8 showed maximum airborne asbestos concentrations in United States

schools up to 0.0023 f/mL (by transition electron microscopy, >5 μm in length).

There was no correlation between asbestos concentration in air and type and

condition of asbestos-containing material present (materials containing asbestos

included insulation, lagging, acoustic ceilings, tiles); whether the space was covered;

whether sweeping was noted; type of school or year of construction; or air flow in the

same area.

Risk management

Occupational health and safety legislation in each state and territory and the Code of

Practice for the Safe Removal of Asbestos covers the management of asbestos-

containing materials in public and commercial buildings. Non-occupational exposure

can be minimised by ensuring compliance with these regulations.

6 EnHealth, Management of asbestos in the non-occupational environment, Australian Government, 2005

7 Ceiling insulation in approximately 1100 homes in the ACT, since removed, and another 100 or so homes in nearby NSW

towns 8 Corn, M, Airborne concentrations of asbestos in non-occupational environments, Annals of

Occupational Hygiene, 38(4):495–502, 1994.


The HACA has followed a risk management approach based on work health and safety

legislation which requires assessment of the risks, putting in place controls to ensure that

exposure to airborne asbestos fibre is prevented and removal where asbestos materials are

likely to be disturbed during renovation, refurbishment or demolition work. HACA has

provided the following advice:

Loose-fill asbestos was sold as ceiling insulation in the 1960s and 1970s, for

residential and commercial premises mainly by one company trading in the ACT as

Mr Fluffy. While most properties impacted are located in the ACT, a small number of

properties in south east NSW have been identified as containing this type of

insulation.

The insulation is raw asbestos that has been crushed into a fine state and installed in

the ceiling space. This means it is easy to disturb and fibres can become airborne

and easily inhaled or ingested which can cause significant health risks.

Testing of homes with loose-fill asbestos insulation has shown that exposure is likely

to be very low if the asbestos is undisturbed and remains sealed off at all points

where entry of asbestos into living areas can occur (including cornices, architraves,

around vents, around light fittings, manholes and tops of cupboards).

Home owners should not undertake any refurbishment work that requires alteration

to any walls, ceilings, wall sockets or removal of cornices, no cabling (unless surface

mounted) or additional sockets/outlets recessed in walls and avoid accessing

subfloor areas until a further assessment under controlled conditions can be

conducted.

A licensed asbestos assessor or an occupational hygienist will be able to advise you

whether your living spaces are well sealed and asbestos hazards are appropriately

controlled. Only qualified tradespeople with asbestos awareness training can work on

any areas identified with asbestos. Removal of loose-fill asbestos fibres may only be

done by a Class A Licensed Asbestos Removalist.

We also recommend that an asbestos warning sticker be placed in the electrical

meter box to alert any trades people who might attend your property.

(Source: http://www.workcover.nsw.gov.au/formspublications/publications/Pages/loose-fill-asbestos-

insulation.aspx)

http://www.workcover.nsw.gov.au/online-searches/Pages/adl-search.aspx

http://www.workcover.nsw.gov.au/online-searches/Pages/adl-search.aspx

http://www.workcover.nsw.gov.au/formspublications/publications/Pages/loose-fill-asbestos-insulation.aspx

http://www.workcover.nsw.gov.au/formspublications/publications/Pages/loose-fill-asbestos-insulation.aspx


Actions taken by NSW government on loose fill asbestos insulation

The HACA has commissioned an Independent Investigation to help establish the scope and

number of New South Wales properties with loose fill asbestos insulation. The investigation

will review and assess relevant records including inspection reports, risk assessments and

compliance and disposal records. The investigation will commence in October 2014.

A free testing service has been made available to residents in twenty four local government

areas for any suspected loose-fill asbestos insulation in homes built prior to 1980. Samples

are safely collected by WorkCover licensed asbestos assessors contracted through HACA.

To date over 500 residents have taken up the offer of the free sampling service.

The HACA has conducted briefing sessions on loose fill insulation for council staff in all of

the 26 affected local government areas. Local Government NSW has also conducted 14

workshops over the last 18 months with over 430 staff from 130 councils (85%) to provide

asbestos awareness training and briefings on the HACA model asbestos policy for councils.

HACA is working with the following potentially affected councils to provide advice and

guidance on loose-fill asbestos:

1. Albury City Council

2. Bankstown City Council

3. Bega Valley Shire Council

4. Berrigan Shire Council

5. Bombala Council

6. Boorowa Council

7. Cooma Monaro Shire Council

8. Eurobodalla Shire Council

9. Goulburn Mulwaree Council

10. Greater Hume Shire Council

11. Ku-ring-gai Shire Council

12. Lithgow City Council

13. Manly Council

14. North Sydney Council

15. Orange City Council

16. Palerang Council

17. Parramatta City Council

18. Queanbeyan City Council

19. Snowy River Shire Council

20. The Hills Shire Council


21. Tumbarumba Shire Council

22. Upper Lachlan Shire Council

23. Wagga Wagga City Council

24. Warringah Council

25. Yass Valley Shire Council

26. Young Shire Council

Homes identified as containing the material will be offered a free independent technical

assessment to advise on and confirm the adequacy of risk controls in each of the identified

homes. HACA members have met with Queanbeyan residents. Both the testing and

technical assessment services will be available for a 12-month period. The testing protocol

and study findings will be peer reviewed by the Chief Health Officer of NSW’s Expert

Advisory Committee, and informed by a review of the health risk assessment literature for

asbestos.

HACA has funded the Asbestos Project Manager position with Local Government NSW for a

further two year period.

HACA, through WorkCover NSW, has committed over $700,000 to fund the above initiatives.

HACA has developed the following information which is available on the HACA webpage:

Factsheet – Information for residents

Frequently asked questions

Information on the safe management of loose-fill asbestos insulation

Queanbeyan study

The Queanbeyan City Council has run previous free home testing services in the past, in

conjunction with the local area health service and is currently offering rate relief for residents

where financial hardship can be established.

HACA is seeking advice on the methods for appropriately notifying future purchasers of

homes identified as containing loose-fill asbestos insulation. The Conveyancing Act 1919

requires certain documents to be attached to a contract of sale, including a planning

certificate issued under s149 of the Environmental Planning and Assessment Act 1979.

A planning certificate is issued by a council and provides advice on certain matters relating

to the land, such as planning restrictions and controls, hazards and other relevant matters

affecting the land, which the council may be aware of.

Additionally, the provisions of the Conveyancing Act requires the vendor and their agent to

disclose certain information during a property transaction, and HACA is seeking advice as to

whether this duty to disclose also applies to disclosing the presence of loose-fill asbestos

insulation where it has been positively identified.


WorkCover has been in contact with Fire and Rescue NSW and the State Emergency

Service (SES) and provided information on dealing with loose fill asbestos including a list of

affected properties. Fire and Rescue NSW and SES have both updated their emergency

procedures and systems to ensure emergency services workers are aware when

responding.

Number of homes with loose fill asbestos insulation

Asbestos insulation was used as a fire retardant and insulation material in buildings up until

the late in 1970s. Many companies installed sprayed insulation onto structural steel work to

achieve fire rating building requirements for commercial construction. Non-asbestos

containing loose fill insulation was widely installed in homes during this period and continues

with many contractors having similar names such as “insulfluff” or “aussie fluff insulation”,

“magic fluff insulation” to name a few non-asbestos insulation providers.

This can create confusion amongst consumers about what material they have in their ceiling.

Non-asbestos cellulose insulation can look very similar to loosefill asbestos insulation.

Loosefill asbestos was sold as residential ceiling insulation In the 1960s and 1970s, mainly

by one Australian Capital Territory (ACT) contractor, Mr Jansen who traded as Asbestosfluf

Insulation and J&H Insulations but also known as “Mr Fluffy”. While most properties are

located in the ACT, to date only a small number of properties in south east NSW have been

identified as containing this type of insulation.

Number of homes in NSW

The HACA is coordinating an independent Investigation into the number of houses in NSW

and is offering a free testing service in 26 local government areas.

The government areas have been selected based on reference material from NSW Health

records and information from the ACT Government that suggests “Mr Fluffy” may have

worked or transported loose fill asbestos to these regions.

To date, 21 domestic premises including an apartment block of 38 units have been identified

as containing loose fill asbestos insulation in New South Wales. One of the properties in

Orange since demolished was recorded as having loose fill insulation removed prior to

demolition.

Queanbeyan City Council – 14 (2 remediated)

Yass Valley Shire Council – 1


Palerang Council - 1

Orange Council – 1 (demolished)

Lithgow Council – 1

Bankstown Council – 1 (remediated / demolished)

Parramatta Council – 1 (remediated)

Manly Council – 1 (remediated)

As at 27 October 2014, there have been 502 requests for ceiling insulation testing as set out

in the table below. Results from the testing were not available at the time of the preparation

of this submission.

COUNCIL REGION # of Request

1. Wagga Wagga City Council 96

2. Queanbeyan City Council 70

3. Ku-ring-gai Shire Council 61

4. Yass Valley Shire Council 44

5. Cooma Monaro Shire Council 32

6. The Hills Shire Council 32

7. North Sydney Council 22

8. Bega Valley Shire Council 16

9. Young Shire Council 16

10. Goulburn Mulwaree Council 16

11. Palerang Council 14

12. Snowy River Shire Council 13

13. Eurobodalla Shire Council 12

14. Warringah Council 12

15. Orange City Council 10

16. Bankstown City Council 10

17. Bombala Council 7

18. Boorowa Council 5

19. Upper Lachlan Shire Council 5

20. Berrigan Shire Council 4

21. Albury City Council 2

22. Greater Hume Shire Council 1

23. Lithgow City Council 1

24. Tumbarumba Shire Council 0

25. Manly Council 0

26. Parramatta City Council 0

Grand Total 502


Number of homes and action taken in other jurisdictions

Australian Capital Territory

The Commonwealth/ACT governments identified over 1,050 residences in the ACT

which have been identified as having loose fill asbestos insulation.

The $100 Million Commonwealth/ACT program to remove ceiling insulation from ACT

houses between 1988 and 1993 was not successful. Although the ceiling spaces were

remediated, asbestos material remained lodged in wall cavities, sub-floor spaces and

underneath cornices. The removal of loose fill from ceiling cavities did not remove the

hazard and may have given a false sense of security that the asbestos hazard had been

eliminated.

The ACT Government has responded by establishing an Asbestos Response Taskforce,

which is providing financial assistance to affected homeowners. Payments include:

up to $10,000 to families that are unable to live in their homes as a result of an

asbestos assessment,

plus an additional $2,000 per dependent child

reimbursement of the costs of asbestos assessments,

up to $1,000 for replacement of goods and clothing, and

reimbursement of gap payment for doctor visits.

The assistance package also includes the bulk purchase of asbestos assessments for the

affected homes. The ACT Government will also waive disposal fees where houses

containing loose fill asbestos are renovated or demolished. A range of options are also

available to assist those who may be experiencing distress9.

The ACT Government has agreed to accept a concessional loan of $1 billion from the

Commonwealth to pay for the voluntary purchase of up to 1,049 houses which will be

remediated and demolished. The vacant land will be resold. The scheme will be run over 5

years and commences in 2015. The NSW government is liaising with the Commonwealth

regarding assistance, which will be dependent on the outcomes of the current investigation

into the number of affected homes in NSW.

United States of America

Tremolite asbestos contaminated vermiculite loose-fill insulation (approximately 1%

contamination), sourced from Libby Montana, was used extensively in attics and walls in the

9 http://www.act.gov.au/asbestos-response-taskforce#assistance

http://www.act.gov.au/asbestos-response-taskforce#assistance


USA up until the 1990’s with reports that millions of homes are affected. The United States

Environmental Protection Agency (EPA) advice is provided in Attachment A.

The EPA recommends the materials be left undisturbed in attics (ceiling spaces) and walls

and does not fund asbestos testing or removal. The US Federal Government conducted a

national consumer awareness campaign in 2003 advising homeowners of the hazards and

risk control measures for loose-fill insulation provided in Attachment B.

There are no known financial support arrangements to householders by governments in the

United States of America.

United Kingdom & Northern Ireland

The United Kingdom Health and Safety Executive (HSE) advises that loose-fill asbestos

insulation can be found in lofts (ceiling spaces), walls and floor cavities of homes in the

United Kingdom provided in Attachment C. The number of affected houses is not known.

The HSE focus is on the safety of workers and provides risk management advice on the safe

management of asbestos materials for workers. Individual councils provide general asbestos

information to householders and there are no known government funded schemes for testing

or removal of asbestos from houses.

Canada

WorkSafe British Columbia advises on the use of loose-fill asbestos contaminated

vermiculite insulation in Canadian homes provided in Attachment D. The number of affected

houses is not known. There are no known government funded schemes for testing or

removal of asbestos from houses.


Asbestos control framework – the role of state, local governments and property owners

The statutory framework for control of asbestos in New South Wales encompasses

Commonwealth, State and Local Government legislation for work health and safety,

planning, environmental protection, consumer safety, import/export controls and

compensation for asbestos-related diseases.

Role of governments

The HACA has prepared the Asbestos Blueprint which maps out the roles and

responsibilities of NSW government organisations at each stage of the asbestos lifecycle

and provides background information, control frameworks, scenario maps and outcomes to

address the identification and management of:

asbestos in the workplace

asbestos in residential settings

transport and disposal of asbestos

asbestos in the ground and site contamination

emergency management

prohibitions on the manufacture and supply of asbestos.

The Asbestos Blueprint can be found at

http://www.workcover.nsw.gov.au/formspublications/publications/Documents/heads_asbesto

s_coordination_authorities_asbestos_blueprint_3508.pdf

A summary of roles and responsibilities are provided in the table below.

http://www.workcover.nsw.gov.au/formspublications/publications/pages/headsofasbestoscoordinationauthoritiesasbestosblueprint.aspx

http://www.workcover.nsw.gov.au/formspublications/publications/Documents/heads_asbestos_coordination_authorities_asbestos_blueprint_3508.pdf

http://www.workcover.nsw.gov.au/formspublications/publications/Documents/heads_asbestos_coordination_authorities_asbestos_blueprint_3508.pdf



Asbestos prohibition

In 2001 the former body to Safe Work Australia declared a prohibition on all uses of

chrysotile asbestos from 31 December 2003, subject to a very limited range of exemptions,

and confirmed earlier prohibitions of the use of amosite and crocidolite asbestos. The

prohibition of chrysotile was adopted simultaneously under regulations in each Australian

work health and safety jurisdiction, as well as Australian Customs, on 31 December 2003.

The prohibition does not extend to Asbestos Containing Materials in situ at the time

prohibition took effect so does not prohibit the presence of material such as loose-fill

asbestos.

Asbestos management requirements

If asbestos or asbestos containing material (ACM) is identified in a workplace (which may

include a domestic residence) and demolition or refurbishment work is going to be carried

out, the asbestos or ACM must be removed if it is likely to be disturbed before the work

starts. If other maintenance or service work is to be carried out at the workplace, removal of

asbestos should be considered as a control measure.

Under the national model work health and safety regulations workplaces are required to

have an asbestos register and an asbestos management plan. This is not required for

residential premises except where they become a place of work under the Work Health and

Safety legislation.

The national model work health and safety legislation require the management of the risks

associated with asbestos through:

identifying asbestos and ACM at the workplace and recording this in the asbestos

register

assessing the risk of exposure to airborne asbestos

eliminating or minimising the risks by implementing control measures

reviewing control measures to ensure they are effective.

When choosing the most appropriate control measure, the following hierarchy of controls

must be considered:

eliminating the risk (for example, removing the asbestos)

substituting the risk, isolating the risk or applying engineering controls (for example,

enclosing, encapsulation, sealing or using certain tools)

using administrative controls (for example, safe work practices)

using PPE.


Where removal is not reasonably practicable, other control measures must be implemented

to minimise exposure, including encapsulation or sealing. A combination of these controls

may be required in order to adequately manage and control asbestos or ACM.

Airborne respirable fibre concentrations can be estimated using available data (for example,

monitoring reports, data from scientific literature) or past experience (for example, monitoring

reports) of the process in question. In cases of doubt, it may be necessary to confirm the

estimates by measurement using the Guidance Note on the Membrane Filter Method for

Estimating Airborne Asbestos Fibres [NOHSC: 3003 (2005)].

Air monitoring is carried out if it is not certain whether or not the concentration of an airborne

contaminant exceeds the relevant exposure standard or to determine whether there is a risk

to health, air monitoring can also be used for a number of other reasons including:

helping to choose the best exposure minimisation controls

checking existing controls are working effectively.

Exposure measurement must not be used as an alternative to controlling exposure by

putting in place hazard controls. Air monitoring is best done after control measures have

been put in place. Compliance with the WHS legislation will require being able to

demonstrate all reasonably practicable hazard controls are in place and effective and that

attempts have been made to eliminate or minimise exposure, as well as not exceeding the

relevant exposure standard.

Where the results show that respirable asbestos fibre levels exceed the action levels

outlined in the table below, action must be taken immediately.

Action level Control Action

Less than 0.01 fibres/ml

No new control measures are necessary Continue with control measures

At 0.01 fibres/ml or more than 0.01 fibres/ml but less than or equal to 0.02 fibres/ml

1. Review

Review control measures

2. Investigate

Investigate the cause

3. Implement Implement controls to eliminate or minimise exposure and prevent further release

More than 0.02 fibres/ml

1. Stop removal work Stop removal work

2. Notify regulator Notify the relevant regulator by phone followed by fax or written statement that work has ceased and the results of the air monitoring


Action level Control Action

3. Investigate the cause Conduct a thorough visual inspection of the enclosure (if used) and associated equipment in consultation with all workers involved with the removal work

4. Implement controls to eliminate or minimise exposure and prevent further release

Extend the isolated/barricaded area around the removal area/enclosure as far as reasonably practicable (until fibre levels are at or below 0.01 fibres/ml, wet wipe and vacuum the surrounding area, seal any identified leaks (e.g. with expandable foam or tape) and smoke test the enclosure until it is satisfactorily sealed

5. Do not recommence removal work until further air monitoring is conducted

Do not recommence until fibre levels are at or below 0.01 fibres/ml

When a person has been engaged to conduct demolition or refurbishment at a domestic

premise, it becomes the workplace of that person. Consequently, that person must identify

and, if necessary, remove asbestos before work commences. The Work Health and Safety

Regulations place no duties on the homeowner.

Demolition – A person who is engaged to conduct demolition work at a house

(which has become their workplace) must identify asbestos under their management

or control that is likely to be disturbed by the demolition work. They must ensure, so

far as is reasonably practicable, that the asbestos is removed before the work

commences. If an emergency occurs, the person carrying out the demolition work at

the domestic premise must ensure, so far as is reasonably practicable, that before

the demolition work starts a procedure is developed that will explain how to minimise

the risk of exposure of workers and persons in the vicinity of the demolition site and

ensure the exposure standard is not exceeded, so far as is reasonably practicable.

The person must also provide the regulator with written notice of the emergency

immediately after they become aware of the emergency and before the demolition

starts.

Refurbishment – A person who is engaged to conduct refurbishment work at a

house (which has become their workplace) must identify asbestos under their

management or control that is likely to be disturbed by the refurbishment work. They

must ensure, so far as is reasonably practicable, that the asbestos is removed.


Asbestos removal requirements

Asbestos removal is regulated under the Work Health and Safety Act 2011 and the

Environmental Planning and Assessment Act 1979 for friable asbestos removal, with some

exemptions for Exempt Development. There are two types of licences: Class A and Class B.

Type of licence What asbestos can be removed?

Class A Can remove any amount or quantity of asbestos or asbestos containing material (ACM), including:

any amount of friable asbestos or ACM

any amount of asbestos-contaminated dust or debris (ACD)

any amount of non-friable asbestos or ACM.

Class B Can remove any amount of non-friable asbestos or ACM

No licence required Can remove:

up to 10 m2 of non-friable asbestos or ACM

ACD that is:

o associated with the removal of less than 10 m2 of non-friable asbestos or

ACM o not associated with the removal of friable or non-friable asbestos and is

only a minor contamination.

A person commissioning licensed asbestos removal work must ensure that, once the

licensed asbestos removal work has been completed, a clearance inspection is carried out

and a clearance certificate is issued before the workplace can be re-occupied by:

an independent licensed asbestos assessor, for work that must be carried out by a

Class A licensed asbestos removalist (for example, if the removal work involved

friable asbestos)

an independent competent person, for asbestos work that is not required to be

carried out by a Class A licensed asbestos removalist (for example, if removal work

involved more than 10 m² of non-friable asbestos).

This also includes where the work is being carried out at domestic premises.

The independent licensed assessor or competent person must not issue a clearance

certificate unless they are satisfied that the asbestos removal area and the area immediately

surrounding it are free from visible asbestos contamination. To do this, they can conduct a

visual inspection for evidence of dust and debris. If air monitoring was also conducted, the

results of that test must show that asbestos is below 0.01 fibres/ml.

If a clearance certificate has not been obtained, the asbestos removal area must not be

re-occupied for normal use. A clearance certificate must be issued before the area can be

re-occupied for demolition or other work.


Coordination arrangements

The Heads of Asbestos Coordination Authorities (HACA) is chaired by the Chief Executive

Officer of Safety, Return to Work and Support of which WorkCover NSW is an agency with

representatives from:

Department of Trade and Investment Regional Infrastructure and Services

Department of Planning and Environment

Environment Protection Authority

Local Government NSW

Ministry of Health

Ministry for Police and Emergency Services

Office of Local Government

Workers' Compensation Dust Diseases Board.

The Heads of Asbestos Coordination Authorities (HACA) Charter sets out the arrangements

for the coordination of the activities of statutory authorities in relation to all aspects of

asbestos information, assistance, compliance and enforcement.

The Charter aims to ensure that New South Wales Government agencies and councils

effectively coordinate the safe management of asbestos at all stages of the asbestos

lifecycle and across the policy areas of workplace health and safety, public health and

environment protection.

The Charter objectives are to establish a practical overarching framework for liaison between

Government agencies and councils concerned in the management of asbestos to:

a) Ensure the effective coordination of strategies for the safe management of asbestos.

b) Promote the identification, safe containment and safe disposal of asbestos materials

to help prevent asbestos-related diseases by including a comprehensive public

awareness and educational campaign.

c) Ensure close cooperation to maximise effectiveness and minimise duplication of

regulatory effort.

d) Ensure that individuals, workers, organisations and statutory authorities have access

to consistent and accurate information to provide a clear understanding of the roles

and responsibilities of each Government organisation.

e) Facilitate an open and collaborative approach that promotes prompt and effective

action on asbestos issues and provides an environment for continuous learning and

the application of those learning outcomes through improved public policy, disease

prevention advice, and control strategies.

http://www.trade.nsw.gov.au/

http://www.planning.nsw.gov.au/

http://www.environment.nsw.gov.au/

http://www.lgnsw.org.au/

http://www.health.nsw.gov.au/

http://www.emergency.nsw.gov.au/home.html

http://www.dlg.nsw.gov.au/dlg/dlghome/dlg_index.asp

http://www.ddb.nsw.gov.au/Pages/home.aspx


State-wide asbestos plan

The State-wide Asbestos Plan launched in April 2013 aims to secure the safe management

of asbestos to reduce the incidence of asbestos-related diseases in NSW and targets

actions around the four priority areas:

Research – improved understanding of asbestos issues

Risk communication – increased awareness and knowledge

Prevention – protection of workers, the community and the environment

Coordination – responsive planning, regulation and services

The Implementation Plan has been developed for 62 initiatives in the four priority areas.

A table of key actions that were undertaken during 2013 is contained in the 2013 Annual

Report available at www.workcover.nsw.gov.au.

Model policy for NSW councils

The HACA in partnership with Local Government NSW (LGNSW), has developed a Model

Asbestos Policy for NSW Councils to provide councils with the basis for the preparation of a

http://www.workcover.nsw.gov.au/


comprehensive and compliant asbestos policy. It outlines important legislative obligations of

councils and provides useful additional information.

The Model Asbestos Policy has been issued to all councils by the Division of Local

Government under section 23A of the Local Government Act 1993.

LGNSW has held fourteen Asbestos Management Workshops across NSW to support

councils in adopting the Model Asbestos Policy.

The workshops give participants the opportunity to explore the roles and responsibilities of

councils in safely managing asbestos and features expert presenters, council case studies

and group activities to help outline useful strategies.

Information on Loose fill asbestos is included in the Model Asbestos Policy and in the Local

Government Fact Sheet. Councils are encouraged to update their policies with information

about loose fill asbestos and over 75% of councils have a draft or final asbestos policy

based on the model policy.

Asbestos awareness campaign

The HACA, in partnership with the Asbestos Education Committee (AEC) and the Asbestos

Diseases Research Institute (ADRI), co-funds the annual Asbestos Awareness Campaign.

The campaign aims to alert Australians about the dangers of working with asbestos during

home renovations and maintenance and has included:

campaign theme and slogan – Renovation Roulette (example below)

update of the asbestosawareness.com.au website including a new site for mobile

device use

‘Betty the ADRI House’ campaign tour to metropolitan, regional and rural NSW

(further details below)

funding of a safety awareness segment on the Better Homes and Gardens lifestyle

program on national television which aired on 1 November 2013

community and council engagement

Blue Lamington morning teas for asbestos awareness

securing support from Bunnings Warehouse for point of sale asbestos safety

information

media kit development, distribution and case study engagement

development of promotional materials

lighting of Opera House Sails and candlelight tribute for those people affected by

asbestos-related disease

Asbestos Ambassador engagement


Source: Asbestos Education Committee in partnership with the Asbestos Diseases Research Institute

‘Betty the ADRI House’ campaign

Betty the ADRI House was launched during Asbestos Awareness Week in November 2012

and is the first of her kind in Australia. She is a community engagement and experiential

awareness initiative of the Asbestos Education Committee in partnership with the ADRI.

Betty is a purpose built, mobile model home designed to demonstrate where asbestos might

be found in and around any Australian home built or renovated before 1987. Her exterior

resembles a typical fibro home … but when opened up, she has extensive audio and visual

information including a bathroom, kitchen, living room, man shed/garage and a dog house.

Betty visits communities around Sydney and New South Wales, primarily to community

events, council activities and DIY or renovation expos educating Australians about asbestos

dangers.

In July 2013, Betty embarked on her first regional tour of Northern New South Wales and in

August toured through the Central West and Blue Mountains region. Betty covered more

than 3800 kilometres and covered over 26 communities.

During the Asbestos Awareness Month Campaign in November, Betty travelled 2438

kilometres and made 29 individual appearances. To ensure local community engagement,

Betty was hosted by 17 councils around NSW.


The Asbestos Awareness Campaign has received the support of Bunnings Hardware Stores

and Betty has made appearances at over 19 store locations including: Penrith, Warrawong,

Shell Harbour, Mittagong, Rouse Hill, Bonnyrigg, Gosford, Lakehaven, Thornleigh, Narellan,

Port Stephens, North Parramatta, Villawood, Seven Hills, Campbelltown, Minchinbury,

Caringbah, Bankstown and Liverpool.

Betty has also attended a number of events including the Royal Easter Show (2013), Sydney

HIA Home Show, AgQuip, National Asbestos Conference Sydney, Lighting of Sails at

Circular Quay, ADFA Memorial Day at Darling Harbour, Ausgrid Learning and Development

Centre and the Endeavour Energy Learning and Development Centre. Traffic to the

asbestosawareness.com.au website increases when Betty is on tour.

Since the launch of Betty and the campaign, the number of visits to the website increased by

186.7% with total number of visits since launch reaching more than 85,000 and achieving

more than 400,000 page views.

Asbestos Ambassador engagement

The Asbestos Awareness Campaign was once again fortunate to have the ongoing support

of our Asbestos Ambassadors and home renovation media personalities: Don Burke, John

Jarratt, Scott Cam, Scott McGregor, Cherie Barber and Lindsay Farris. Our Ambassadors

attended events and conducted media interviews.

Blue Lamington morning teas for asbestos awareness

The Blue Lamington morning teas were offered during asbestos awareness month as an

opportunity for workplaces to informally discuss issues about asbestos safety at work and in

the home.


Print, radio and television community service announcements or publicity materials were

distributed to radio, TV and media outlets. In NSW the advertisements were aired as

community announcements on Channels 7, 9 and 10, and radio stations 2GB, 2CH and

Koori Radio.

Renovation Roulette

The Renovation Roulette campaign for 2012 won the 2014 Global Alliance COMM PRIX

Award of Distinction in Madrid, Spain on 22 September 2014. The Global Alliance COMM

PRIX Awards are the only global awards which honour outstanding performance in public

relations and communication management around the world.

Further information

The Heads of Asbestos Coordination Authorities will be pleased to provide additional

information to the Committee as required.


ATTACHMENT A — United States Environmental Protection Agency – vermiculite insulation advice.

If You Have Vermiculite Insulation YOU SHOULD ASSUME THE VERMICULITE

CONTAINS ASBESTOS AND DO NOT DISTURB IT!

Any disturbance could potentially release asbestos fibres into the air. If you absolutely have

to go in your attic and it contains vermiculite insulation, you should limit the number of trips

you make and shorten the length of those trips in order to help limit your potential exposure.

We recommend that you:

Leave vermiculite insulation undisturbed in your attic or in your walls.

Do not store boxes or other items in your attic if it contains vermiculite insulation.

Do not allow children to play in an attic with vermiculite insulation.

Do not attempt to remove the insulation yourself.

Hire a professional asbestos contractor if you plan to remodel or conduct renovations

that would disturb the vermiculite in your attic or walls to make sure the material is

safely handled and/or removed.

Source: http://www2.epa.gov/asbestos/protect-your-family-asbestos-contaminated-vermiculite-insulation#risk

Does the EPA have money available for homeowners to pay for asbestos testing or

asbestos removal?

The EPA does not have funding available to homeowners for asbestos testing or removal.

Source: http://toxics.supportportal.com/link/portal/23002/23019/Article/33674/-Does-the-EPA-have-money-available-for-homeowners-to-pay-for-asbestos-testing-or-asbestos-removal

http://www2.epa.gov/asbestos/protect-your-family-asbestos-contaminated-vermiculite-insulation#risk

http://www2.epa.gov/asbestos/protect-your-family-asbestos-contaminated-vermiculite-insulation#risk

http://toxics.supportportal.com/link/portal/23002/23019/Article/33674/-Does-the-EPA-have-money-available-for-homeowners-to-pay-for-asbestos-testing-or-asbestos-removal




ATTACHMENT B — United States Environmental Protection Agency Advice – vermiculite insulation campaign

Consumer Awareness Campaign Launched on Vermiculite Insulation Used in

some Home Attics

Release Date: 05/21/2003 Contact Information:

CONTACT: David Deegan 202-564-7839

(05/21/03) The federal government today launched a national consumer awareness

campaign to provide homeowners with important information on vermiculite attic insulation

which may contain asbestos. This new campaign, coordinated by EPA and the Agency for

Toxic Substances and Disease Registry (ATSDR), instructs homeowners on how to identify

vermiculite attic insulation and recommends that people make every effort to not disturb it.

Since some vermiculite attic insulation can contain very low levels of microscopic asbestos

fibres, it is important that consumers are aware of the precautions they can take to protect

against disturbing and inhaling the asbestos fibres.

“The government believes that people should be aware that some vermiculite attic insulation

can contain microscopic asbestos fibres, and there are practical steps that homeowners can

take to minimize exposure. People who have homes with vermiculite attic insulation should

become informed, not alarmed,” said Stephen L. Johnson, EPA’s Assistant Administrator for

the Office of Prevention, Pesticides, and Toxic Substances. “By using the information in this

campaign, people can determine if their home contains vermiculite attic insulation and learn

how to properly manage it. Well informed consumers can reduce the possibility for exposure

to asbestos from vermiculite attic insulation and minimize potential risks.”

The key recommendations for homeowners to minimize exposure are:

Homeowners should not disturb vermiculite attic insulation. Any disturbance has the

potential to release asbestos fibres into the air.

If homeowners must go into attic space with vermiculite insulation, they should make

every effort to limit the number, duration, and activity level of those trips. Boxes or

other items should not be stored in attics if retrieving them will disturb the insulation.

Children should not be allowed to play in an attic with open areas of vermiculite

insulation.


Homeowners should never attempt to remove the vermiculite insulation. If removal is

necessary, hire professionals trained and certified to safely remove the material.

If you plan to remodel or conduct renovations that would disturb the vermiculite, hire

professionals trained and certified to handle asbestos to safely remove the material.

Due to the scientific uncertainties associated with existing testing techniques, there is no

easy way or dependable testing method to differentiate between vermiculite insulation that

might have some asbestos fibres and vermiculite insulation that does not. Home testing

vermiculite in attics is not currently practical.

Therefore, it is best to assume that the material may contain asbestos and take the

appropriate precautions. That is why EPA and ATSDR are today going forward with this

consumer awareness campaign for homeowners that will allow them to identify the presence

of vermiculite insulation in their attics, and if they have it, how best to reduce their potential

exposure to the asbestos it may contain.

The campaign includes the nationwide distribution of a joint EPA and ATSDR pamphlet that

outlines how to identify and manage vermiculite. The pamphlet will be disseminated to the

national news media and through major hardware store chains, and through prominent

display on EPA’s website: http://www.epa.gov/asbestos/. Information is also available to

consumers at a special hotline:1-800-471-7127.

Source:

http://yosemite.epa.gov/opa/admpress.nsf/177f410e8a398c0f85257021005643a7/6c0c8d7c

7db067e085256d2d005d3efb!opendocument

http://www.epa.gov/asbestos/

http://yosemite.epa.gov/opa/admpress.nsf/177f410e8a398c0f85257021005643a7/6c0c8d7c7db067e085256d2d005d3efb!opendocument

http://yosemite.epa.gov/opa/admpress.nsf/177f410e8a398c0f85257021005643a7/6c0c8d7c7db067e085256d2d005d3efb!opendocument


ATTACHMENT C — United Kingdom Health and Safety Executive Advice

Where is asbestos found?

Asbestos could be present in any building that was built or refurbished before the year 2000.

1. Water Tank: Is usually made of asbestos cement and is often found in older properties (pre 1980).

2. Pipe Lagging: Asbestos insulation on pipes. Used to keep heat in or cold out. Often painted over or protected by outer coating so not obviously asbestos.

3. Property Insulation: Loose asbestos can be found as insulation in wall and floor cavities and in lofts.

4. Textured coating (eg artex): Can be found throughout property on ceilings and sometimes walls.

5. Soffit Board (roof overhang): Soffit board sits behind fascia at eaves level. Board can be made from asbestos cement or asbestos insulating board.

6. Toilet cistern: Toilet cisterns can contain asbestos-reinforced resin composite materials.

7. Wall Panelling: Asbestos can be found as external wall cladding and as internal wall panelling both particularly around windows.

8. Fuse box: Often found in hall or under stairs. Each fuse wire has an individual asbestos flash guard. Panel behind fuse box can be asbestos.

9. Heater Cupboard: Heater cupboard around domestic boiler often contains asbestos insulating board.

10. Floor tiles: Vinyl and thermoplastic floor tiles can contain asbestos. The tile backing may also contain asbestos paper.

11. Rainwater items: Roof gutters and down pipes can often be made of asbestos cement.

Source: http://www.hse.gov.uk/asbestos/hiddenkiller/where-is-it-found-html.htm

http://www.hse.gov.uk/asbestos/hiddenkiller/where-is-it-found-html.htm


ATTACHMENT D — WorkSafe British Columbia, Canada Advice

Until the early 1980s, many products containing asbestos were used in house construction.

Some products, such as asbestos-containing vermiculite insulation, were used in homes

right up until the late 1980s. The drawing in this pamphlet shows many possible sources of

asbestos in older homes. When you are renovating or demolishing an older house, there is a

high probability of encountering asbestos containing materials. If asbestos-containing

materials are in good condition and left intact, they do not pose a significant danger of

releasing asbestos fibres into the air you breathe. However, these materials are hazardous

when they deteriorate or are disturbed, such as when they are handled, sanded, drilled into,

or broken up so that they crumble. To avoid disturbing asbestos-containing materials, you

must know where they are before you begin renovations.

The diagram below illustrates the use of loose, blown-in insulation in Canadian homes..

Source: http://www.worksafebc.com/publications/health_and_safety/by_topic/assets/pdf/asbestos_hazards_homeowners.pdf

http://www.worksafebc.com/publications/health_and_safety/by_topic/assets/pdf/asbestos_hazards_homeowners.pdf